Ed. Note: if you’re new to TURBOFAC, please take note that the text string filtration function generally shouldn’t be used for terms such as “ordinarily resident,” “causing” or “new debt”. For research on the meaning of words and phrases such as those, i.e. terms central to the key legal issues in sanctions law that appear on a cross-programmatic basis, you’re typically better off locating and checking the appropriate box in the “Key Legal Issues” search category, which will limit the results to those that have been manually assessed as being relevant for the interpretation of the terms at issue.
Try typing your search term (“ordinarily resident,” “new debt,” or something else) in the “Find a Search Filter” box at the top of the page, and the corresponding “Key Legal Issues” check box will pop up instantly, if one exists. Once you check the box (e.g. “new debt,” with ~55 results), you can always use the text string filtration function to further refine your search (e.g. by typing “invoice” and narrowing the ~55 results to ~10).
Note in addition that the same applies to text string searches such as “14071” (if you’re looking for items related to EO 14071). By typing “14071” in the “Find a Search Filter” field up top, you will be able to instantly narrow the results down to items manually assessed as relating to EO 14071. Ditto terms such as “515.204” or “Iran General License G” (try the “Discrete Legal Provision” search category).
Please contact [email protected] or [email protected] with any questions on search results and efficiency.
Please click "Apply Text String Filters" again after clicking the "Close" button immediately below.
1) BACKGROUND
This guidance letter is notable as one of the few applications of the blocking prohibition to a tricky trust-related set of facts.
The relevant factual background, of which some is relayed by OFAC but other aspects are found in the court filings in the litigation associated with the guidance letter, is as follows: in October, 1999, Abdala Luis Saieh Jassir established a trust fund, with himself as Settlor and “First Union Bank and Trust Company (Cayman) LTD,” a Cayman Islands entity, acting as trustee (see p. 40, native PDF file). The Trust (called JAMCE Trust) was a revocable trust, set so that “upon the death of the Settlor, the Trustee…shall distribute the undisposed part of the Trust Fund to the Settlor’s children in equal shares…” (P. 41, 58). The Trust Deed called for the Trustee to incorporate a Cayman Islands company...